BACKGROUND:
Zenith Procurement Limited (“Zenith”) understands that your privacy is important to you and that you care about how your personal data is used. Zenith respect and value the privacy of everyone who visits this website, www.zenproc.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand. Your dealings with Zenith will be deemed acceptance of this Privacy Policy.
1. Information About Us
Our Site is owned and operated by Zenith Global Procurement Limited, a limited liability company registered in England & Wales under registration number 12593521.
Registered address: 7 Bell Yard, London WC2A 2JR
Data Protection Officer: Gregory Mappledoram.
Email address: gregory@zenproc.com.
Telephone number: +44 7408870000.
2. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the UK Information Commissioner’s Office.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
5. What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.
Data Collected
Identity Information: including name and title
How We Collect the Data
Enquiries through Our Site or when you contact us.
Data Collected
Contact information: including address, email address, telephone number social media contact details.
How We Collect the Data
Enquiries through Our Site or when you contact us.
Data Collected
Business information: including business name, job title, professional profile.
How We Collect the Data
Enquiries through Our Site or when you contact us.
Data Collected
Technical information: including IP address, browser type & version, operating system.
How We Collect the Data
Accessing Our Site, through Cookies and analytical tools.
Data Collected
Data from third parties: including technical information, name and contact information.
How We Collect the Data
Accessing Our Site, through Cookies and analytical tools.
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
What We Do
Administering Our Site.
What Data We Use
Technical Information
Data from third parties
Our Lawful Basis
(a) Necessary for legitimate interests (for running the business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation.
What We Do
Administering our business.
What Data We Use
Technical Information
Data from third parties
Identity Information
Contact Information
Business Information
Our Lawful Basis
(a) Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation.
What We Do
Supplying our products and services to you.
What Data We Use
Identity Information
Contact Information
Business Information
Our Lawful Basis
(a) Performance of business services with you
(b) Necessary for our legitimate interests
(c) Necessary to comply with a legal obligation.
What We Do
Communicating with you.
What Data We Use
Identity Information
Contact Information
Business Information
Our Lawful Basis
(a) Performance of business services with you
(b) Necessary for our legitimate interests
(c) Necessary to comply with a legal obligation.
What We Do
Supplying you with information by email.
What Data We Use
Identity Information
Contact Information
Business Information
Our Lawful Basis
(a) Performance of business services with you
(b) Necessary for our legitimate interests
(c) Necessary to comply with a legal obligation.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Type of Data
Identity Information.
How Long We Keep It
Only for so long as a business relationship exists and as legally required thereafter.
Type of Data
Contact information
How Long We Keep It
Only for so long as a business relationship exists and as legally required thereafter.
Type of Data
Business information including
How Long We Keep It
Only for so long as a business relationship exists and as legally required thereafter.
Type of Data
Technical information including
How Long We Keep It
Only for so long as a business relationship exists and as legally required thereafter.
Type of Data
Data from third parties.
How Long We Keep It
Only for so long as a business relationship exists and as legally required thereafter.
8. How and Where Do You Store or Transfer My Personal Data?
We will store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
We may also store or transfer some or all of your personal data in countries that are not part of the EEA, including South Africa. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We may also share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
We may also share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguard is applied to such transfers:
·Our contracts with external third parties require the same levels of personal data protection that would apply under the Data Protection Legislation.
· Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
· Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
· Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
· If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
· In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
· We may share your personal data with other companies in our group for provision of business support, marketing or additional business opportunities. This includes any holding company and its subsidiaries.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the Data Protection Legislation, as explained above in Part 9.
10. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or at the point of providing your details).
11. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
13. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We may use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. In addition, Our Site may use analytics services. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site.
For the purposes of this Privacy Policy Cookies means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.
14. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Gregory Mappledoram)
Email address: info@zenproc.com.
15. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 18 Feb 2024..
© 2020-2024 Zenith Procurement Limited. All Rights Reserved
Copyright © 2020-2024 Zenith Global Procurement Limited - All Rights Reserved.
